In short: importing herbal extracts from India into the EU is very manageable if you plan for five things. First, check that the ingredient is allowed as food in your country and is not a novel food. Second, test every batch for ethylene oxide, pesticide residues, heavy metals and, where relevant, PAHs, pyrrolizidine alkaloids and microbes. Third, know whether your product falls under the EU's increased border checks. Fourth, collect a complete document set. Fifth, label and market the finished product within EU food supplement and health claim rules. The EU importer is legally responsible, so most of this is agreed with your supplier before the order is placed.
Who is responsible when you import into the EU?
In the EU, the company that places the product on the market is responsible for its safety and compliance. For imported herbal extracts, that is usually the EU importer, registered as a food business operator in its member state. Your Indian supplier provides the product, specification and test reports; you, or your customs broker and importer of record, provide the EU registration, the EORI number for customs, and the final market checks. Agreeing who does what, in writing, before the first order avoids most problems at the border.
Step 1: Check the ingredient is allowed
- Novel food status. Under Regulation (EU) 2015/2283, a food not consumed to a significant degree in the EU before 15 May 1997 needs authorisation as a novel food. Many traditional herbs are fine, but some plants, plant parts or new extraction methods are not. Check the European Commission's Novel Food Catalogue for the plant and the part you are buying.
- National plant lists. Several member states keep their own lists of plants allowed, restricted or banned in food supplements. Belgium, France and Italy, for example, use a shared list known as BELFRIT. A plant that is fine in one country can be restricted in another.
- Food or medicine? Some botanicals at certain doses or with certain claims are treated as medicines in some countries. Selling as a food supplement only works if the product, dose and claims stay within food law.
Step 2: Test for what the EU actually checks
This is where most shipments from any origin fail, and where a careful supplier makes the biggest difference. The main limits are set in Regulation (EU) 2023/915 on contaminants and Regulation (EC) No 396/2005 on pesticide residues.
| What is tested | EU rule | What to ask your supplier for |
|---|---|---|
| Ethylene oxide (ETO) | Banned for use in food in the EU; limits are set at the level a lab can detect, measured as ethylene oxide plus 2-chloroethanol (0.1 mg/kg for herbs and spices) | A batch test report for ETO and 2-chloroethanol, and written confirmation that ETO is not used for sterilisation |
| Pesticide residues | Maximum residue levels under Reg. 396/2005; 0.01 mg/kg default for pesticides without a specific limit | A multi-residue screen (LC-MS/MS and GC-MS/MS) on the batch |
| Lead | 3.0 mg/kg in food supplements | An ICP-MS heavy metal report with numbers, not just "complies" |
| Cadmium | 1.0 mg/kg in food supplements (3.0 mg/kg for products mostly made of dried seaweed) | |
| Mercury | 0.10 mg/kg in food supplements | |
| Pyrrolizidine alkaloids | 400 µg/kg in food supplements containing botanical preparations, including extracts | A PA test for at-risk plants and blends |
| PAHs | Maximum levels for benzo(a)pyrene and the sum of four PAHs in botanical supplements and dried spices | A PAH test, especially for dried, roasted or smoked materials |
| Microbes | Salmonella must be absent; other counts to specification | Total plate count, yeast and mould, E. coli and Salmonella results |
| Mycotoxins | Aflatoxin and ochratoxin A limits for spices such as ginger and turmeric | Aflatoxin and ochratoxin results for spice-based extracts |
Two points matter more than any single number. First, the result must relate to your batch, not a generic report from last year. Second, limits apply to the product as sold. An extract can concentrate both the good compounds and the contaminants, so a clean raw herb does not guarantee a clean extract. If you're unsure how to read the results, our guide on how to read a COA goes through it line by line, and steam sterilisation vs ETO vs irradiation explains the treatment options.
Ethylene oxide is the single biggest risk for herbs and spices from India. Since the 2020 sesame seed case, EU authorities have tested for it routinely, and one positive result can mean a recall of every product made with that batch.
Step 3: Know whether your product faces increased border checks
Regulation (EU) 2019/1793 lists foods from certain countries that face a higher rate of identity and physical checks at the EU border, with a fixed percentage of consignments sampled. Several Indian products are on that list, mainly for pesticide residues, aflatoxins and ethylene oxide. Since 2025, food supplements containing botanicals from India have been listed for ethylene oxide checks. Spices such as cumin and nutmeg are listed for other hazards.
If your product is listed, the consignment must be pre-notified on a Common Health Entry Document (CHED-D) in the EU's TRACES system, enter through a designated border control post, and in some cases travel with an official certificate and lab results from India. The list is updated regularly; the most recent update at the time of writing is Regulation (EU) 2026/194. Always check the current version, or ask your customs broker, before shipping.
Step 4: Collect the right documents
- Commercial invoice and packing list, with the botanical name, batch numbers and HS code (plant extracts usually fall under heading 1302)
- Certificate of analysis for each batch, with numeric results for the marker, identity, heavy metals, microbes and loss on drying
- Contaminant reports: ethylene oxide and 2-chloroethanol, pesticide multi-residue, and PAH or pyrrolizidine alkaloids where relevant
- Product specification sheet: plant part, solvent, extract ratio or standardisation, carrier and test methods (see our guide to extract ratios and standardised extracts)
- Certificate of origin
- Statements on allergens, GMO status, irradiation and, if requested, BSE/TSE and residual solvents
- Organic certificate and electronic certificate of inspection (COI) in TRACES, if you are importing as organic
- Bill of lading or air waybill, and the CHED-D reference if the product is under increased checks
On irradiation: in the EU, only dried aromatic herbs, spices and vegetable seasonings may be irradiated, in an EU-approved facility, and the product must be labelled as irradiated. Herbal extracts are not on that list, so ask for a written statement that the extract has not been irradiated.
Step 5: Label and sell within EU rules
- Food supplements follow Directive 2002/46/EC. Many member states require you to notify the competent authority before the product goes on sale, with a copy of the label.
- Labelling follows Regulation (EU) No 1169/2011: the name, ingredients, allergens, net quantity, best-before date, the food business operator's name and address, and, for supplements, the recommended daily dose and the required warnings, in the language of each country of sale.
- Health claims are controlled by Regulation (EC) No 1924/2006. Most claims for botanicals are still "on hold" at EU level and are handled differently by member states. Avoid disease claims entirely, and have every claim checked for your target market.
Step 6: Shipping and customs
Most herbal extracts travel as dry powder in 25 kg fibre or HDPE drums with double food-grade liners, by sea for regular orders or by air for samples and urgent stock. Agree the Incoterm (EXW, FOB, CIF or DAP) and who handles the CHED-D and customs clearance. Your importer needs an EORI number, and the shipment needs the HS code and the documents above. Keep the extract cool and dry in transit, and check the seals and labels on arrival before the batch is released.
Why EU shipments get stopped
The EU's Rapid Alert System for Food and Feed (RASFF) publishes every notification. For herbs, spices and botanical ingredients, the same causes come up again and again:
- Ethylene oxide or 2-chloroethanol found above the limit
- Pesticide residues above the EU maximum, often from substances not approved in the EU
- Aflatoxins or ochratoxin A in spices and roots
- Salmonella in dried plant material
- Unauthorised novel food or a plant not allowed in the country of sale
- Missing or wrong documents for products under increased checks
All of these are preventable with a batch-specific test plan agreed before production and a supplier who shares real numbers.
EU vs USA: the key differences
| European Union | United States | |
|---|---|---|
| Who is responsible | EU importer as food business operator | US importer under FSVP, plus FDA-registered foreign facility |
| Before shipping | CHED-D in TRACES if under increased checks | FDA Prior Notice for every food shipment |
| Ethylene oxide | Banned for food use; tested at the border for listed products | Permitted as a fumigant on some spices within tolerances |
| Novel ingredients | Novel food authorisation if not consumed before 1997 | New dietary ingredient notification if not marketed before 1994 |
| Health claims | Authorised list only; most botanical claims on hold | Structure/function claims with the FDA disclaimer |
For the US side in detail, see our guide on how to import herbal extracts from India to the USA.
Buying for the EU from Arizone
Arizone International LLP manufactures and exports herbal extracts, herb powders, oils and private label capsules under ISO 22000:2018, GMP, FSSAI and HACCP, with a certificate of analysis for every batch. When you enquire for the EU, tell us the product, grade, quantity and destination country, and list the tests your importer requires. We will confirm the specification, the reports available for your batch, and any extra testing before shipment. We supply export customers only, in the EU, the UK, the USA, the Middle East, Australia and 40+ other countries.
Sources: Regulation (EU) 2023/915 on contaminants in food; CBI: buyer requirements for herbs and spices in Europe; AGRINFO: increased official controls, January 2026 update.
EU Import Questions
Yes. Herbal extracts from India are imported into the EU every day. The extract must be allowed as food in the country of sale, meet EU limits for contaminants such as ethylene oxide, pesticides and heavy metals, and travel with the right documents.
Ethylene oxide is banned for use in food in the EU. Limits are set at the lowest level a laboratory can reliably measure, calculated as ethylene oxide plus 2-chloroethanol; for herbs and spices this is 0.1 mg/kg.
Under Regulation (EU) 2023/915, food supplements may contain up to 3.0 mg/kg lead, 1.0 mg/kg cadmium (3.0 mg/kg for supplements made mostly of dried seaweed) and 0.10 mg/kg mercury.
A Common Health Entry Document for food of non-animal origin, filed in the EU's TRACES system before a consignment arrives. It is required for products listed for increased official controls, so that the border control post can plan checks.
It depends on the plant, the part used and the preparation, and some member states also restrict certain plants in supplements. Check the European Commission's Novel Food Catalogue and the national rules of each country of sale before you launch.
A commercial invoice, packing list, certificate of analysis and certificate of origin come with every shipment. Tell us the tests your importer needs, such as ethylene oxide, pesticides or heavy metals, and we will confirm the reports available for your batch before shipment.